SUBJECT:
SUBJECT: IMPACT OF SPCC RULE REVISION
EFFECTED FACILITIES: CLIENTS USING PETROLEUM PRODUCT BULK STORAGE
REFERENCE: 40 CFR 112, Final Rule Revision, July 17, 2002
BACKGROUND
The USEPA modified the referenced rule (67FR47042, July 17, 2002, "Oil Pollution Prevention and Response Non-Transportation-Related Onshore and Offshore Facilities") effecting the Spill Control and Countermeasure (SPCC) Plans and secondary containment of all facilities that store in excess of 1320 gallons of petroleum products.
Important milestones under the rules:
FR (68 FR18894, 4/17/03). Extended the original compliance dates. The new dates are:
|
All Effected Facilities review and revise SPCC Plans: |
by August 17, 2004 |
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Implement all Secondary Containment associated with Review: |
by February 16, 2005 |
AVAILABLE ENGINEERING & TANK SERVICES:
- Rule requires that the review and revision of SPCC Plans must be done by a P.E.
- AGES can provide the review and plan revisions. Assess facility needs to comply.
- AGES can provide design of required secondary containment.
- AGES can, where appropriate, document the "not practical" provision of the rules where secondary containment is impractical.
- AGES can evaluate drainage areas not controlled by diking and recommend changes.
- AGES can provide tank and piping NDT inspections using API and/or PADEP standards.
- AGES can provide tank cleaning & NDT inspection services as a turn-key project.
- AGES can perform permeability testing (falling head) of containment area floors constructed of compacted soil/clay materials. Meets PADEP inspection requirements for containment areas.
- AGES can provide installation or retrofit of clay carpet liners to upgrade containment area floors to meet permeability state specifications.
- AGES can design warning and level alarm systems required by SPCC rules.
- AGES can design containment systems for Mineral Oil containing Electrical Equipment
MATERIALS CONSIDERED PETROLUEM PRODUCT UNDER THE RULE
- Fuel Oils – All Types
- Gasoline
- Kerosene
- Lubricating Oils
- Hydraulic Oils – Petroleum Based
- Waste Oils
- Mineral Oils
EFFECTED UNITS WITHIN FACILITIES
- Those Bulk Storage Tanks not already having secondary containment.
- Electrical Equipment containing Mineral Oil Dielectric fluids, if the facility is already above the bulk storage tank quantities.
- Petroleum product unloading and loading racks.
- Wastewater treatment plants used as Secondary Containment.
- Piping that transfers petroleum products.
- Cathodic protection for underground piping.
- Underground secondary containment units – Steel requires cathodic protection
- Oil/Water Separators. Partial Exemption.
CLIENT FACILITIES NEEDING REVIEW AND POSSIBLE UPGRADING
- Fuel Oil Fired Utility Stations
- Electrical Equipment at Utility Stations subject to SPCC for bulk storage
- Auxiliary Fuel Systems at Coal & Nuclear Stations
- Steel Plants – Boiler fuel storage, Blast Furnace Auxiliary fuel storage tanks Hydraulic Systems, Wastewater Treatment Facilities
- Chemical Plants – Boiler Fuel storage
- Refining Facilities – Bulk Storage, API Separators
- Industrial Facilities – Boiler Fuel Storage, Product Heating Furnaces
- Fuel Distributors – Bulk Storage & Distribution Facilities